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Commentary

266.2 Roll-over relief for schemes of reconstruction

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

266.2 Roll-over relief for schemes of reconstruction

| Commentary

266.2 Roll-over relief for schemes of reconstruction

Shareholders will generally be able to claim to be treated as exchanging their original shares in one company (Company A) for the new shares issued by another (Company B) as part of a scheme of reconstruction1. As a result, payment of capital gains tax will be delayed until the shareholders dispose of their Company B shares. The basic conditions for the relief are that2:

  1. 266.2.1

        there is an arrangement between Company A and its shareholders or debenture holders, or any class of them, which is entered into for

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